-69-                                                   
            properties.  He and these entities were also heavily involved in                            
            a number of condominium conversion projects in various cities                               
            around the country, in many of which Prudential held interests.                             
            Mr. Frey and his related entities shared certain fees with Kanter                           
            and his related entities, which respondent also contends                                    
            constituted part of the kickback scheme.                                                    
                  (3) William D. Schaffel.  Mr. Schaffel was a mortgage broker                          
            and real estate developer.  Mr. Schaffel also assisted a New                                
            Jersey general contracting company to obtain certain construction                           
            contracts.  From 1979 through 1986, he had extensive business                               
            dealings on behalf of individuals he represented with Prudential                            
            and Travelers.  Mr. Schaffel shared with Kanter and his related                             
            entities brokerage and development fees, which respondent claimed                           
            was part of the kickback scheme.                                                            
                  (4) Property Management Systems, Inc. (PMS).  The chairman                            
            and chief executive officer of PMS was Kenneth Schnitzer.  PMS                              
            managed office buildings and other commercial real estate for                               
            others pursuant to property management contracts.  A relatively                             
            small portion of its business included contract cleaning or                                 
            janitorial services on some Texas commercial properties it                                  
            managed.  At one point, IRA acquired and owned a 47.5-percent                               
            stock interest in PMS.  Certain fees of PMS were also shared with                           
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